Justia Constitutional Law Opinion Summaries

A Rhode Island oral and maxillofacial surgeon, Dr. Stephen T. Skoly, refused to comply with a COVID-19 Emergency Regulation issued by the Rhode Island Department of Health (RI DOH) that required all healthcare workers and providers to be vaccinated against COVID-19. Following his public declaration of noncompliance, the RI DOH issued a Notice of Violation and Compliance Order against him. Skoly then filed a lawsuit in federal court against the state and its officials, alleging violations of equal protection, due process, and First Amendment rights. The district court dismissed his complaint under Federal Rule of Civil Procedure 12(b)(6).The district court's decision was based on the fact that the state officials were either entitled to absolute or qualified immunity for their actions. The court held that the RI DOH directors were exercising prosecutorial authority delegated to them by Rhode Island law, thus granting them absolute immunity. As for Governor McKee, the court found that he was protected by qualified immunity as Skoly had no clearly established right to continue practicing while violating the vaccine mandate. The court also rejected Skoly's First Amendment retaliation claim, stating that the posting of the Notice constituted government speech, which could not form the basis of a plausible First Amendment retaliation claim.Upon appeal, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Skoly's complaint. The appellate court agreed with the lower court's findings that the state officials were entitled to either absolute or qualified immunity and that Skoly's constitutional claims were without merit. The court also upheld the dismissal of Skoly's First Amendment retaliation claim, stating that Skoly had not sufficiently alleged that he was targeted due to his opposition to the First Emergency Regulation. View "Skoly v. McKee" on Justia Law

The case involves Jennifer Root Bannon, who sued six law enforcement officers and the City of Boston on behalf of her brother's estate. Her brother, Juston Root, was fatally shot by the officers after a series of events that began with him pointing a gun at a hospital security guard and a responding police officer, leading the officers on a high-speed chase, and disregarding police instructions to drop his weapon. Bannon claimed that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the defendants.The United States Court of Appeals for the First Circuit agreed with the district court's conclusion that the officers acted reasonably under the circumstances during the fatal shooting and did not violate the Fourth Amendment. The court also held that the officers were entitled to qualified immunity and affirmed the grant of summary judgment on Bannon's other claims. The court found that no reasonable jury could conclude that the officers acted unreasonably in employing deadly force against Root in violation of the Fourth Amendment. The court also independently concluded that the officers were entitled to summary judgment on Bannon's § 1983 and MCRA claims based on qualified immunity. View "Bannon v. Godin" on Justia Law

The United States Court of Appeals For the First Circuit examined a case where the defendant, Derek Gerrish, challenged the constitutionality of a search of his vehicle during his pretrial release on several state criminal charges. During this period, Gerrish was subjected to at least six different bail conditions, five of which allowed for searches of his person, vehicle, or residence at any time without reasonable suspicion. The search in question led to the discovery of fentanyl and other contraband, resulting in Gerrish pleading guilty to possession with intent to distribute fentanyl.Gerrish argued that the search of his vehicle was unconstitutional, despite the terms of his bail conditions. The district court denied his motion to suppress the evidence, citing two reasons: the officers had reasonable suspicion of criminal activity, and Gerrish's bail conditions permitted such a search.On appeal, the defendant argued that both of the district court's reasons were incorrect. The appeals court, however, only focused on the bail condition rationale, as it found it conclusive. The court noted that Gerrish knowingly agreed to bail conditions authorizing searches without suspicion and did not challenge the reasonableness of these conditions. Furthermore, it emphasized that the issue at hand was not the search itself, but the bail conditions that authorized it.The court rejected Gerrish's argument that such bail conditions could not be imposed pre-trial or pre-guilty plea, referring to precedent which stated that acceptance of such conditions significantly diminishes a defendant's reasonable expectation of privacy. It also dismissed Gerrish's claim of a conflict with a Ninth Circuit decision, stating that Maine law requires "least restrictive" bail conditions tailored to the defendant's individual circumstances, thereby eliminating the Ninth Circuit's concerns about mandatory waiver of rights.The judgment of the district court was thus affirmed. View "United States v. Gerrish" on Justia Law

This appeal, heard by the United States Court of Appeals for the First Circuit, centered on the constitutionality of Massachusetts' Law 80, which retroactively provided immunity to higher education institutions for monetary damages due to actions taken in response to the COVID-19 pandemic. The plaintiffs, students at Boston University (BU), had sued the university for breach of contract and unjust enrichment following BU's transition to remote learning during the Spring 2020 semester. They contended that they had paid for in-person instruction and services, which BU failed to provide.The lower court ruled in favor of BU, holding that the university was entitled to the defense of impossibility as it had to comply with COVID-19 emergency orders. On appeal, the court was required to consider whether the retroactive application of Law 80 to the case violated the Due Process Clause of the United States Constitution.The appellate court found that Law 80 served reasonable public interests related to public health, safety, future compliance, and economic consequences beyond the control of the universities. The court also determined that the plaintiffs' alleged implied contract rights did not constitute vested rights. Furthermore, the court noted that the scope of Law 80 was appropriately limited and did not excessively burden the plaintiffs.Consequently, the court held that Law 80 does not violate due process and affirmed the lower court's judgment, ruling in favor of BU. The court did not need to consider the merits of the lower court's decision to exclude the plaintiffs' expert witness's testimony. View "Dutra v. Trustees of Boston University" on Justia Law

In this case, the United States Court of Appeals for the First Circuit examined an appeal against a district court's refusal to issue a preliminary injunction against the enforcement of a Rhode Island law banning certain large-capacity ammunition magazines. The plaintiffs, a group of gun owners and a registered firearms dealer, argued that the law infringed upon their Second Amendment rights, as well as their rights under the Fifth and Fourteenth Amendments.The Court of Appeals, however, upheld the district court's decision. It noted that the law did not impose a significant burden on the right of armed self-defense, as it did not prevent gun owners from owning other forms of weaponry or ammunition, and the banned magazines were rarely used in self-defense situations. Furthermore, the court found that the law was consistent with a longstanding tradition of regulating firearms in the interest of public safety.The court also rejected the plaintiffs' arguments that the law was retroactive and vague, violating their Fourteenth Amendment rights. It concluded that the law was not retroactive as it did not impose new liability on past actions, and it was not unconstitutionally vague as individuals of ordinary intelligence could understand what it prohibited. The court also found that the plaintiffs were unlikely to succeed on their Fifth Amendment claims, as the law did not effect a physical or regulatory taking of their property. View "Ocean State Tactical, LLC v. Rhode Island" on Justia Law

In Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC, the United States Court of Appeals for the First Circuit was asked to determine whether a Rhode Island truck dealer could challenge a ruling by a Rhode Island state agency that it lacked jurisdiction to grant relief for alleged violations of a Rhode Island law regulating motor-vehicle dealers and manufacturers. The violations in question were committed by an out-of-state truck manufacturer. The plaintiff, Rhode Island Truck Center, LLC ("RITC"), argued that the manufacturer's establishment of a dealership outside of Rhode Island violated the law and harmed RITC's business. The District Court granted summary judgment to the manufacturer, Daimler Trucks North America, LLC, arguing that the state agency lacked authority to apply Rhode Island law extraterritorially.The Court of Appeals concluded that it had subject-matter jurisdiction over the case under the federal-question jurisdiction. The court then certified a question of state law to the Rhode Island Supreme Court concerning whether a "relevant market area" specified in Rhode Island law could extend beyond Rhode Island's borders. The court affirmed the District Court's grant of summary judgment on another claim, where RITC challenged the Board's dismissal of a claim related to Daimler's denial of a Western Star franchise to RITC. The court held that the District Court did not err in concluding that the relief requested would have an extraterritorial effect that violated the Dormant Commerce Clause. View "Rhode Island Truck Ctr v. Daimler Trucks North America" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

In this case, Grace Katana appealed his conviction for conspiracy to interfere with interstate commerce by robbery in violation of the Hobbs Act. He argued that the indictment accused him of conspiring to rob Joseph Wilson, while the government only proved at trial that he had planned a break-in at Wilson's home. Katana claimed that this constituted a constructive amendment to the indictment in violation of his constitutional rights, that there was a prejudicial variance from the charge in the indictment, and that there was insufficient evidence to support his conviction.The United States Court of Appeals for the First Circuit rejected Katana's arguments and affirmed his conviction. The court found that the offense charged in the indictment was the same offense on which the court instructed the jury and on which the government presented evidence. The court also held that the identity of the robbery target was not an element of a robbery or conspiracy to commit robbery under the Hobbs Act, so focusing on Wilson's home business as the target at trial did not amount to a constructive amendment. The court further concluded that Katana failed to demonstrate that any variance from the indictment was prejudicial, as the record showed he had sufficient notice of, and was able to defend himself against, the government's theory at trial. Finally, the court ruled that a rational jury could have concluded that Katana and his co-conspirators planned to rob Wilson's home business, so there was sufficient evidence to support his conviction. View "US v. Katana" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, the defendant, Randall Crater, was convicted of wire fraud, unlawful monetary transactions, and operating an unlicensed money transmitting business based on his involvement in a cryptocurrency scheme. The trial lasted eight days and was based on Crater's management of My Big Coin (MBC), a cryptocurrency company that allegedly misrepresented itself as a gold-backed digital currency and claimed a partnership with MasterCard. The defendant appealed two of the district court's rulings.Firstly, Crater argued that the district court violated his Sixth Amendment right to compulsory process by refusing to enforce subpoenas against three federal agency witnesses due to Crater's non-compliance with the agencies' Touhy regulations. Secondly, Crater contended that the district court did not perform its gatekeeping duty by admitting testimony from the government's cryptocurrency expert without holding a Daubert hearing.However, the Court of Appeals affirmed the district court's decision, stating that Crater's arguments could not be reconciled with controlling precedent or the record in the case. The court found that Crater's failure to show how the excluded testimony of the federal agents would have been both material and favorable to his defense invalidated his Sixth Amendment claim. Furthermore, the court held that Crater's objections to the expert witness's qualifications and methodology were insufficient to necessitate a Daubert hearing. View "US v. Crater" on Justia Law

The case concerns the appeal of Gilbert Perez, who sought to have his federal drug conviction overturned on the basis that the United States District Court for the District of Maine had incorrectly denied his motion to suppress the outcomes of a warrantless search of his backpack. Perez argued that the search was not justified under the search-incident-to-arrest exception to the warrant requirement of the Fourth Amendment to the U.S. Constitution. The District Court, relying on a previous case (United States v. Eatherton), had upheld the search. Perez contended that subsequent Supreme Court decisions had undermined the validity of Eatherton.On the night of his arrest, Perez had been seen acting suspiciously in a McDonald’s parking lot in Lawrence, Massachusetts. When he left the lot, carrying a backpack, he was monitored by state troopers. He was seen exiting a taxi, and large quantities of cash were found in the vehicle, arousing suspicion that he had been involved in a drug transaction. When Perez returned to the McDonald’s lot, he was approached by Trooper Jason Conant, who identified himself as a state trooper. Perez ran but was caught, and the backpack was removed from him and searched. The search revealed it contained fentanyl and cocaine. Perez was subsequently indicted on a federal drug-related charge.In his appeal, Perez maintained that the backpack's search was a violation of the Fourth Amendment. The United States Court of Appeals for the First Circuit disagreed, affirming the judgement of conviction. It concluded that neither of the Supreme Court cases cited by Perez had invalidated the Eatherton ruling. The panel also rejected the notion that Perez's backpack could be considered separate from his person at the time of arrest. As such, it fell within the search-incident-to-arrest exception to the Fourth Amendment's warrant requirement. View "US v. Perez" on Justia Law